1. About this Policy
- This policy explains when and why we collect personal information about our students and instructors, how we use it and how we keep it secure and your rights in relation to it.
- We will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. Further details on the GDPR can be found at the website for the Office of the Data Protection Commissioner in Guernsey (www.odpc.gg). For the purposes of the GDPR, we will be the “controller” of all personal data we hold about
2. Who are we?
- We are the Guernsey Sailing Trust LBG (‘Trust’). We can be contacted at The Boat House, Castle Emplacement, St Peter Port, Guernsey GY1 1AU / Email – firstname.lastname@example.org / Tel – 01481 710877.
3. What information we collect and why.
|Type of information||Purposes||Legal basis of processing|
Student’s name, address, telephone numbers, e-mail address(es) and any relevant medical condition.
Managing the Student’s course booking with the Trust.
|Performing the Trust’s contract with the Student for the purposes of our legitimate interests in operating the Trust.|
|Emergency contact details.||Contacting next of kin in the event of emergency.||Protecting the Student’s vital interests.|
|Date of birth / age related information.||
Managing student categories which are age related and issuing age related certificates.
|Performing the Trust’s contract with the Student.|
|Photos and videos of Students.||Putting on the Trust’s website and social media pages and using in press releases.||Consent. We will seek the Student’s or Parent’s/Guardian’s (if under 18 years of age) consent on their Booking Form and the Student or Parent/Guardian (if under 18 years of age) may withdraw their consent at any time by contacting us by e-mail or letter.|
|Bank account details of the Student or other person making payment to the Trust where a refund payment is due to them by the Trust.||Managing the Student’s provision of services and events.||Performing the Trust’s contract with the Student.|
|The Student’s name, address, telephone numbers and e-mail address(es), whilst a current student and for as long as is necessary to comply with our legal obligations.||Passing to the RYA for the RYA to conduct surveys of Students and former students of the Trust. See paragraph 5.3 below.||
For the purposes of our legitimate interests in operating the Trust and
/ or the legitimate interests of the RYA in its capacity as the national body for all forms of boating.
Instructor’s name, address, telephone numbers, email address(es), and relevant qualifications and/or experience.
|Managing instruction at the Trust.||For the purposes of our legitimate interests in ensuring that we can contact those offering instruction and provide details of instructors to students.|
|Name, e-mail address and telephone number of each employee of the Trust.||Information published on Trust’s website, in Trust’s newsletter and other publications, in the Trust’s marketing materials and made available to the RYA, in each case as a point of contact at the Trust.||For the purposes of our legitimate interests in operating and promoting the Trust.|
Employees and representatives of suppliers to the Trust.
|Entering into and managing arrangements with suppliers.||Entering into and performing contracts with suppliers.|
4. How we protect your personal data
- We will not transfer your personal data outside the EU without your
- We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or
- Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100%
- For any payments which we take from you online we will use a recognised online secure payment
- We do not store credit card details nor do we share customer details with any 3rd parties
- We will notify you promptly in the event of any breach of your personal data which might expose you to serious
5. Who else has access to the information you provide us?
- We will never sell your personal We will not share your personal data with any third parties without your prior consent (which you are free to withhold) except where we are required to do so by law or as set out in the table above or in paragraphs 5.2 and 5.3 below.
- We may pass your personal data to third parties who are service providers, agents and subcontractors to us for the purposes of completing tasks and providing services to you on our behalf (e.g. to print newsletters and send you mailings). We do this for the purpose of our legitimate interests in operating the Trust and for performing our contract with you. However, we disclose only the personal data that is necessary for the third party to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own purposes. It is possible that third parties may themselves engage others (sub- processors) to process your data. Where this is the case third parties will be required to have contractual arrangements with their sub-processor(s) that ensure your information is kept secure and not used for their own
- We may also pass your personal data to the RYA for the purposes of carrying out surveys when it is in the legitimate interest of the Trust and the RYA to do so. The RYA may use third parties to carry out the surveys but disclose only the personal data that is necessary for the third party to do so and will have a contract in place that require the third party to keep your information secure and not to use it for their own
6. How long do we keep your information?
- We will hold your personal data on our systems for as long as you are a student/customer of the Trust and for as long afterwards as it is in the Trust’s legitimate interest to do so or for as long as is necessary to comply with our legal obligations. We will review your personal data every year to establish whether we are still entitled to process If we decide that we are not entitled to do so, we will stop processing your personal data except that we will retain your personal data in an archived form in order to be able to comply with future legal obligations e.g. compliance with tax requirements and exemptions, and the establishment, exercise or defence of legal claims.
- We securely destroy all financial information once we have used it and no longer need
7. Your rights
- You have rights under the GDPR:
- to access your personal data.
- to be provided with information about how your personal data is
- to have your personal data
- to have your personal data erased in certain
- to object to or restrict how your personal data is
- to have your personal data transferred to yourself or to another business in certain
- You have the right to take any complaints about how we process your personal data to the Data Protection Commissioner, The Office of the Data Protection Commissioner, St Martin’s House, Le Bordage, St Peter Port, Guernsey GY1 1BR / Email – email@example.com / Tel – 01481 742074.
For more details, please address any questions, comments and requests regarding our data processing practices to The Office Manager, Guernsey Sailing Trust LBG, The Boat House, Castle Emplacement, St Peter Port, Guernsey GY1 1AU / Email – firstname.lastname@example.org / Tel – 01481 710877.